Privacy Policy

Also known as the "Addendum‌ regarding ‌data‌ ‌processing".

Index

Index        1

Definitions        2

Introduction        3

Collected data        4

Overview        4

Usage and connection data        4

Account and/or profile data from third party services        5

How data collection works        5

Cookies        6

Types of cookies        6

Cookie lifetime and blocking        6

Usefulness of cookies        6

Authentication cookies        6

Personalization cookies        7

Statistical and audience measurement cookies        7

Third party advertising cookies        7

Other third party cookies        7

Conclusion on Third Party Cookies        7

Local storage        8

ID number of your devices        8

Data processing, for what purposes?        8

In general terms        8

In order to communicate with you        9

For Advertising, Statistical or Commercial Purposes        9

For Location Purposes        9

For security control purposes        10

Data Recipients        10

Partners        10

Iframes        11

Partner for our emails        11

Social networks and authentication services        11

Recipients related to content effectiveness analysis        12

Legal addressees        12

New owner        13

Security and access        13

Data Retention        14

Advertising        14

Policies of our Partners        15

Age restrictions and parental control        15

Your Rights        16

Deletion of the Account, details        17

International Data Transfers and Privacy Shield.        17

Account Manager access to your Data        17

Additional information on the processing of your Data        18

Other        18

Jurisdiction        19

Changes to our Policies        19

How to contact us?        19

Definitions

Introduction

Within the framework of the GDPR and data protection regulations and the Federal Data Protection Act (DPA), you will find the necessary information to ensure the proper processing of your Data in the remainder of this document.

Use of our Services implies your consent to the collection, use and processing of data and information from you, your activity on the Services or about you. By accessing and/or using our Services, you confirm and agree to the processing of your Data as defined in this document.

Collected data

We collect data that can not only identify you directly, such as your email, name, etc., but also data that can identify you indirectly. The collected data may be sent to servers located outside of Europe or Switzerland, for example on some of our platforms the host is in France, as for example Google, their services, which we use, transmit data to the United States.

We collect Data as soon as one of our Services is also on another website that you visit, however, without interacting with our Services, this collection is very limited, but it is the duty of the person managing the site where we are integrated to ensure that you accept our conditions before charging our services.

When you interact with our Services, we collect the data necessary for that interaction to take place as desired, for example when you write a comment, we collect, not exclusively, the text of the comment, the time of the comment, the author, etc.

When (and not exclusively) you respond to surveys, post information or texts, change your settings, or contact us, the data provided in these various interactions is collected.

We collect information from or about computers, tablets, telephones, or other devices where you install or access the Services. Your IP address, the identification number of your device or browser, or the characteristics of the device or software through which you access the Services may be collected in order to identify your session, to identify you, to facilitate certain settings (e.g., identify your language) or to show you your active sessions.

We also collect your activities on our Services, such as the frequency and duration of your activities, page views and network status (in order to try to minimise your data download when you are in 3g for example).

When the Platform allows identification to our Services via external services such as (but not limited to) the Twitter Login and you use such services, we collect your ID and username for the service in question. We also collect, if you allow it, information that you agree to share with us, such as your email address or date of birth or the list of your friends.

Note about Tequila, the EPFL service: When you first connect, we collect all the information that Tequila provides us, which we then show you, so that you validate, if you do not validate or refuse, this information is then destroyed from our database. By logging in with Tequila you agree to this procedure.

In general, if you explicitly authorize third party services to share data with us, we may use this data and combine it with other information collected about you. However, we will not access external databases without your consent.

How data collection works

In order to store preferences, and to collect data, we use processes similar to those used by many online companies and services, such as cookies or the following elements. This enables us to improve our Services, but also to protect them or simply to offer them. Thus we also adapt the content and advertising (if activated) to your profile.

Technologies used:

These are small data files stored on your device's hard drive. They allow us to better understand your interaction with our Services or the different usage patterns. Our cookies may store some of your information, such as your username or an identifier. This makes it possible to personalize the content in particular.

Types of cookies

There are several types of cookies, those that allow the Services to work properly, those that allow the Services to be personalized, those that measure audiences, those for advertising or tracking purposes, and those for social networking purposes.

However, all these cookies do not come from the same sources, in fact on the same Platform you can have cookies from us or from our Partners, so we distinguish between internal cookies, deposited by us, and third party cookies, deposited by Partners.

Cookie lifetime and blocking

The lifetime of cookies varies according to their function, indeed some cookies (known as session cookies) do not last longer than the time of your visit, but other cookies, allowing for example to record information during a first visit may persist and thus allow to "remember" your last choices when you return.

With your web browser you normally have the possibility to block cookies on our Platform. However, without cookies, we cannot guarantee that your visit will be successful, as some of our Services may no longer function.

Usefulness of cookies

Internal cookies are essentially functional, here is the list:

They allow you to access your Account and keep your session open from page to page.

They allow you to change some aspects of the platform, such as the language, the state of the chat (open or closed), some security parameters or certain data concerning you, for example to be able to say "Welcome YourName" where YourName is replaced by the value of the cookie.
These cookies may also allow us to display a certain type of content rather than another based on what we know about you, for example, to offer you the category "all posts" rather than the front page category if we see, for example, that you are taking the time to view all the posts.

We may also use cookies for audience measurement or statistical purposes (we do not refer to personally identifiable profiling or tracking).

Third party cookies include cookies from our Partners

Deposited by third party content in our advertising locations, which locations partially fund the Services.

These advertising cookies make it possible to count the advertisements displayed, to identify them, or to count their respective display, as well as the number of people who clicked on them or consulted them, or the number of people who were redirected by these advertisements and the actions taken afterwards on the places where you were redirected. This allows the advertiser to know how much it owes to the various persons concerned by the display of these advertisements or to establish anonymous statistics.

These advertising cookies not only make it possible to prevent the repeated display of the same advertisement, they also make it possible to display content in the advertising slots according to, for example, your location; this is therefore targeted advertising, which you can deactivate.

They are therefore functional cookies, enabling actions such as those defined for internal cookies to be carried out.

To the extent that we do not control the purpose of third party cookies (including third party advertising cookies), they are subject to the policies of the third parties that have deposited them.

Similar to cookies, these technologies store information on your device and may record certain information about your activities and preferences.

Local storage as well as cookies are often accepted by default by your browser, please modify your browser settings to change this. However, no longer accepting cookies and local storage from our Services may affect your ability to access our Services.

These identifiers are used, stored and processed to identify you, so you agree that we may formally identify your device. Third parties we work with may also have access to this data because we use some of their plug-ins on our applications, for example Google Firebase, which allows us to send notifications.

It also collects and processes information such as advertising identifiers or the way your devices interact with our Services.

Data processing, for what purposes?

The data collected allows us to offer personalized and attractive experiences. Depending on your use of our Services, the type of data collection we do may vary. Here are the uses that may include the purposes of data processing:

This enables the improvement and development as well as the provision of the Services. It also makes it possible to monitor the performance of the Services and content, in particular in order to customize them. For example, we may personalize the recommendations we make to you by using this information to better understand how you use or interact with our Services. For example, understanding your interests allows us to offer you the opportunity to join a band fan of Alphorn if we find that you play it.

However, we do not analyze for personalization purposes your private conversations or the text of your comments or posts (this is understood to mean the Platform's post publishing feature and not all of your posts such as a response to a survey or the publication of your friends list, etc.). An anti-spam or security analysis is also performed on these contents, it can also be performed by humans designated by us.

We may use your information to send you communications or information about changes to our Policies and to respond to or contact you if it relates to a request or activity you have undertaken. As for promotional or purely marketing communications, we respect your choice whether or not to receive them as indicated on your profile settings.

The information collected may be used to improve or evaluate our advertising and measurement systems. This allows us to show advertisements that are relevant or adapted to your passions.

However, if we use targeted advertising (this is indicated on the information about this Platform), then you have the choice to disable it.

We disidentify you for some of our internal or external business needs, this includes doing statistics and analysis but also performing administrative tasks or improving our advertising targeting (if enabled). De-identification is the process of anonymizing or aggregating data about you so that it no longer identifies you. Anonymised data may be made public if this is legitimate.

Some of our Services may require your location, as long as you do not explicitly accept the precise location of your device, it will be limited to the city only, especially since we rarely ask you for a more precise location. Locating to the city is useful, in order to offer you local content (or advertising) or to ensure compliance with the geographical restrictions of our rights holders on their content.

In order to ensure the safety and security of our Services, we use the data we collect so that we can audit Accounts and activity and respond accordingly if there is suspicious activity or activity that violates our Policies or is in violation of the law.

Data Recipients

The data we collect about you may be shared with third parties such as Partners, government authorities or service providers and advertisers, and this data may or may not identify you. However, the third parties with whom we share certain data must adhere to strict confidentiality obligations.

In the majority of cases we do not "share" the data as such, but rather access to what can generate it, i.e. you. For example, if a third party plugin is used on our Platform, it is rare that we provide data directly to it, but nevertheless, since it is on our Platform, it can collect data from you directly or indirectly, which is tantamount to being able to qualify as data sharing.

Our Partners allow you to improve the Services or even add options thanks to their various plugins. Information about you can be shared with them, anonymous if the use is not directly related to the operation of our Services, but identifiable if it is (for example, sending a notification requires that Google Firebase, our notification partner, can identify you).

Our Partners may also provide us or our Partners with technical or physical infrastructures, such as assistance in payment processing (Paypal or StarPass for example) or assistance in data analysis and management, but also help us to host and store data, make it accessible, secure it, or provide customer and technical service. However, our Partners respect strict confidentiality obligations in accordance with the law.

When you browse our Services, Iframes may appear and integrate Services that are not ours, these Iframes are easily recognizable by the red banner they carry meaning that the content is from a third party and that you should not share your password. As this content can be freely integrated, neither we nor our Partners are responsible for it. By passing your mouse over, interacting with or simply opening these Iframes, you are then subject to the conditions of use and data processing of the content of these Iframes.


On our applications, the equivalent of
Iframes can also be freely integrated, therefore WebView, which are also indicated as containing content not related to our Services and therefore subject to their own policies.

Google Gsuite/Gmail is our Partner for the sending of our emails, this paragraph is not really relevant as a partner, this contract already defines the rules that apply, but we wanted to make sure a second time that you are aware that even if you do not have a gmail address, gmail, via our sending address, will see our emails and the emails you send to us, pass through their Services.

By sharing content posted on our Services or by using our identification service on other platforms or third party identification services, your activity on our Services and certain login information may be shared with or received by us from such third parties. Data such as your email address, age, etc. may also be shared with these third parties with your consent.

In addition, by visiting our Services while logged on or via third party platforms (such as Google), they may retrieve certain data about your browsing within our Services.

It is strongly recommended that you consult and understand the privacy policies and settings available on the platforms of these third parties, insofar as you have accepted them by registering and logging on to them. This will allow you to understand how they track you on other services such as ours and why there may not be much you can do about it if you want to use their resources.

We may share data collected from or about you in hashed, aggregated or anonymized form to measure and improve the effectiveness of content. In the case of an advertiser, we may indicate how its ads are delivered and how many people viewed them or installed the products being offered after viewing the ad.

We may also disclose demographic or audience measurement information that does not personally identify you to anyone with a valid reason (example: Your video was seen by a 22 year old man from Geneva), this allows us to better identify the audience. (Usually, such a precision is only present in case of real interest, otherwise it will be "Your video was seen by one or more young men from the Geneva area").

All audience measurements, once anonymized, aggregated or chopped, can therefore be shared with those who have an interest in consulting them.

If, in the event of legal proceedings, legislation, or government action, we are required to provide data or information, this may be done, but you may not be informed or given the opportunity to withdraw your consent.

For example, if we seek to protect our legal rights or those of our Partners and those of our shareholders, directors, officers, employees and agents, or if we seek to ensure the safety and security of our users, or if we seek to enforce our Terms of Use, fight fraud, manage risks, or comply with the law or pending legal proceedings, or respond to a government entity, then some of your information may be disclosed in good faith. However, if you are concerned by such disclosure, where possible and legal, we will inform you. This will allow you not only to attempt to overturn the decision in court, but also to provide us with information that may be disclosed to the third parties concerned, in order to possibly prevent such disclosure.

In the event that we spin off some or all of our business, change control, or go bankrupt, we may transfer data about you or provided by you to one or more third parties involved in the transaction, provided that in this case your data will be shared as part of our Services or the Services from which we are splitting off.

In addition, when you explicitly agree to the sharing of certain data with certain parties, then we may do so. (e.g. by allowing a third party to access certain information about you)

Security and access

We make every effort to avoid and minimize the risk that your Data may be lost, damaged, stolen, or misused.

In order to secure your data, we use a number of technical, administrative and physical means to protect your data in our possession.

Only persons who have a legitimate reason to access the data, can have access to your data and/or non-public data.

In order to protect your Data, your connections to access the Services we offer are secured via HTTPS or other similar protocols. In addition, we also hash and encrypt certain sensitive data such as your password. Our firewalls ensure that only persons who can legitimately access the Services and Data can do so.

However, in the 21st century, and as you probably know, even the biggest ones can be flawed. For this reason, we cannot contractually promise you rock-solid security in data transmission and storage. We hope that you can trust us when we tell you that we are doing everything we can, but unfortunately it is impossible for us to guarantee the absolute and infallible security of your data.

If you have an Account on our Services, you can view, download or update your Personal Information online through our Services or by contacting us.

Please note that the Parent Designation feature, as well as the Account Login feature on a page, allows you to access Accounts that are not controlled solely by you as an individual. Thus, Accounts that you give third parties access to in this way may be accessed in whole or in part by these third parties, but you or your parents remain responsible for any actions taken through your Account.

Data Retention

We do not improperly store data, however, we believe that the time it takes to provide our Services may include the fact that some data may still be stored after your Account is deleted, for example for backup or legal purposes, but also simply if a data does not belong to you exclusively. We allow ourselves one year to completely delete your Account if you have requested us to do so, as this allows us to keep our backups for a period of time that we consider reasonable in the event of a problem. Beyond one year, certain anonymised and aggregated data is kept for statistical and other purposes permitted by law.

Advertising

Our Services may display third party advertising, which sometimes allows you to interact with it in the same way as Iframes.

If advertising is enabled, it allows us to provide you with our Services at no additional cost. Please note: Advertising can be activated or deactivated without changing our Policies or requiring us to notify you elsewhere than on this page (domainname/CG).

When viewing an advertisement, if the advertisement is enabled on the Platform, whether or not you click on it, the advertiser or the provider of the technology enabling the display of the advertisement may collect information about you. The processing of data by these third parties is governed by their own privacy policies, so our Policies do not apply.

Policies of our Partners

We do not control the cookies and similar technologies that advertisers and third parties use, and our Policies attempt to incorporate and best represent their practices, however we cannot be held responsible for any discrepancies in the processing of data by such third parties with respect to what is advertised in our Terms of Use. However, if we are informed of any incompatibility with our Policies, we are obliged to update them (at least those that have contractual value) within 7 days (+ the time limit for entry into force of the conditions) after confirmation or to stop collaborating with the Partner in question within the same time limit. As a reminder, we cannot collaborate with Partners who do not comply with strict confidentiality obligations in accordance with the law.

Accuracy: the previous paragraph is intended to protect us, in practice, our Partners are selected and integrated after we have ensured that their practices are in compliance with our Policies, however, as their own policies may change on their side, or as it is not impossible that we have made an error in our interpretation of their practices, it is not impossible that a discrepancy may suddenly arise, therefore, you also agree to comply with the policies of all third parties listed on this page (domainname/CG) as being part of our Partners.

Age restrictions and parental control

If you are a minor and either your country does not have a legal definition of "numerical majority" or you do not have one, then you are not allowed to use our Services or even register or log in without the permission and involvement of a parent or legal guardian.

If you are a parent or legal guardian, you can, not contractually, if the page exists, find more information about your possibilities as a parent on the Platform (domainname/parents).

As legal guardian, you are authorized to, if the plugin allowing it is activated and your child accepts it and is aware of the implications of this action, create a Parent Account, which allows you to access your child's Account at any time. Even if he or she changes his or her password. This is one of the exceptions to the contractual rule that only one individual can access a User Account.

Your Rights

You are under no obligation to provide us with your Data, however, if we do not collect, automatically or otherwise, certain data, it is impossible for us to provide you with some or all of our Services.

Your rights of access, rectification or deletion of the data collected about you are guaranteed, in particular by technical means allowing you from your Account to carry out these actions yourself. Contact us if you are unable to do so.

You may also contact us to set guidelines regarding the disposition of your Personal Data in the event of your death.

Via your profile, you can set your preferences regarding the receipt of emails or communications from us. However, you may not opt-out of receiving absolutely all communications from, because, for an example, deleting your Account will need you to confirm it by email. Other administration stuff may be concerned by same measures.

If you do not wish to receive push notifications on your devices, please disable them for our Services.

If we offer targeted advertising, you have the option to disable it.

you may request access to your Data from us, as well as request the update, deletion, correction or transfer of such information.

Some data may remain in the cache of our servers but also of other users' devices after they have been deleted for a few hours.

If you encounter a problem with one of your rights, please contact us (Of course, just because you have a problem does not mean that we do not respect your rights, it may be that there is a bug or problem on our side, we will do our best to solve it once we have contacted you).

Deletion of the Account, details

You can delete your Account from our Services at any time, this is done via your Account Consequences of. an Account deletion:

Some details on this last point: In order to provide a quality service, we make backups. In the event that at time x you delete your Account, but at time x+1 we suffer a technical failure such as the failure of one of our hard disks and we have to make a restore, if the backup we have is dated x-1, then your Account will reappear. This almost never happens, but it is for these reasons that we are unable to guarantee a complete deletion when you choose to do so. You must therefore ensure yourself that your Account is deleted and does not reappear within one year of your decision. In addition, due to current legislation, or for various purposes such as analysis, accounting, operational operations or other, certain information that can legally be retained may indeed be retained. Also, we will not be held responsible in the event of a problem leading to the inability to delete your Account or some of its data if you have not notified us of the problem and we have not reacted within 7 days.

International Data Transfers and Privacy Shield.

We are committed to respecting your privacy, so we also comply with the provisions of the "Privacy Shield" program between the European Union and the United States, and Switzerland and the United States.

Account Manager access to your Data

The Account Manager has access to all your non-sensitive Data. Sensitive Data in this case includes the following data: email, notifications, IP addresses, location history (unless you have given your explicit consent) (the last known location can be accessed by the Account Manager without your consent, if it is reduced to the location where you were, with your consent it can be more precise).

The Account Manager may, if he wishes, even without any valid reason, delete your Account, insofar as it is he who allows you access to the Platform that he has arranged to set up via our Services.

The Account Manager is one of our Partners, so he must abide by the same rules, he is also required to comply with our Policies and data processing. In addition he has signed a contract with us that guarantees this. In the event of your Account Manager's fault, We will not be held liable.

Additional information on the processing of your Data

On this page (domainname/CG) are listed our Direct Partners, along with their policies when necessary, and the list of all our home-made or integrated plugins. The data not defined as contractual on this page (domainname/CG) are therefore non-contractual (except for elements specified as such in this contract (such as third party policies)) but they can help to remove doubts about potential misunderstandings or doubts about this contract and also to clarify the data processing that we perform, they are therefore to be considered.

The content of this page (domainname/CG) may change (There are often corrections or clarifications that are made, for example, (the simple development of a new plugin, which for example would have no impact on the processing of your data, may modify this page, which is why it is too complicated for us to make it contractual), in the event of legal proceedings that you initiate with us or a complaint on your part, it is your duty to save the current version of the page, in order to be able to rely on it if you wish in your action, if a judge recognized in the current proceedings wishes to rely on your saving, as long as you have confirmed to us that it is indeed the version present at the time of the facts, we will accept that he treats it as contractual, this, in order to give you more rights regarding the processing of your data.

Other

Our Services are also accessible via third party websites or applications or other means operated by other companies.

Our Services also contain links to third party sites or applications that we do not control. Furthermore, we are not necessarily responsible for the appearance of such links on our Services. Therefore, we are not responsible for the policies of the sites or applications to which you are redirected.

Three contractual exceptions to the rule that an Account must be used by a maximum of one natural person:

Forum

Swiss law shall apply. The place of jurisdiction is Ecublens, Vaud.

Changes to our Policies

Our Policies may change from time to time to reflect changes in the law or developments in our Services, or for any other reason deemed relevant. Contractually, it is up to you to consult their version number before each use of our Services. However, without being obliged to do so by this contract, we ensure that we indicate their version number on almost all of our pages and we ensure, through the use of cookies or other means authorised by this contract, that we inform you of this as soon as you visit our Services.

In the event of a material and substantial change in our Policies, a notice will be published on our Services. If you have given us your email, you may be notified by this means as well. Therefore, please keep your information up to date, including your email address.

If our Policies change significantly, the new version will automatically be valid 7 days after their publication. For users with an Account, the new Policies will take effect at the time of registration or consent. This 7-day period may not be respected if the law or security requires a quick change.

How to contact us?

Please refer to the other contact information on this page (domainname/CG).

From the french Version 1.0 of June 16, 2019, available in english since the 14.04.2020

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